The Georgian side has taken responsibility to inform the Revenue Office of the United States (US) about the financial assets of US residents living in Georgia. From September 18, when Parliament of Georgia ratified an agreement on Foreign Account Tax Compliance Act (FATCA) with the US, all Georgian financial institutions,… – Continue reading
(Corrects first and sixth paragraphs to make clear Intertrust does not provide tax advice) (Reuters) – Intertrust, which provides tax and regulatory compliance services to 17,000 companies, said on Monday it will seek an initial public offering (IPO) of shares on the Euronext stock exchange. The Amsterdam-based company did not… – Continue reading
A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading
Accounting firm joined revenue minister at speech while fighting court order Top Conservative cabinet ministers met publicly with senior staff from KPMG’s tax division, and one went so far as to promote the firm, even as the Canada Revenue Agency was alleging the company set up an offshore tax “sham”… – Continue reading
Look out, Thomas Piketty. Here comes Gabriel Zucman. With a slim new book that has the feel of Piketty’s bestselling “Capital in the 21st Century,” Zucman, a baby-faced 28-year-old University of California-Berkeley economist, is taking his own swing at global capitalism. His target: tax havens that he says hide $7.6… – Continue reading
The Grand Duchy of Luxembourg is ranked third in the world for the number of financial institutions per-country that have now signed up to report under the Foreign Account Tax Compliance Act (FATCA). IRS figures report 8,525 Luxembourg firms have registered with the FATCA portal, and the total is surpassed… – Continue reading
1. What is CRS? “CRS” or Common Reporting Standard is a regime developed by the OECD to facilitate and standardise the exchange of information on residents’ assets and income, primarily for taxation purposes, between numerous jurisdictions around the world. Officially referred to as the OECD Standard for Automatic Exchange of… – Continue reading
New Delhi, Sept. 20: A bilateral investment treaty between India and the US is unlikely to be finalised before Prime Minister Narendra Modi’s visit to America later this week. Both Modi and US President Barack Obama have been pushing their respective bureaucracies to prepare the pact. Modi will be in… – Continue reading
Revenue is telling ordinary workers to ‘pay now, argue later’ using new powers to demand tax allegedly owed from years ago – up front Thousands of contractors and freelancers have become ensnared in a £5.5bn tax grab – aimed initially at wealthy tax dodgers – that allows HM Revenue &… – Continue reading
GCC countries are expected to “closely consider” a project that aims to curb perceived tax avoidance by some multi-national companies, according to an international tax expert. Under intense public pressure and unprecedented media focus, leaders of the G20 countries tasked the Organisation for Economic Co-operation and Development (OECD) to come… – Continue reading
The IRS today released an advance version of Notice 2015-66 announcing that the Treasury Department and IRS intend to amend regulations under sections 1471-1474 to extend the time that certain FATCA transitional rules will apply. The notice also addressing the reporting of 2014 information under a Model 1 IGA. Notice… – Continue reading
China’s State Administration of Taxation on 17 September 2015 released a discussion draft of proposed guidance relating to “special tax adjustments”—including those concerning transfer pricing—for public consultation. It is anticipated that this guidance could be finalized by the end of 2015, and once final, would replace the existing transfer pricing… – Continue reading
THE proposed Income Tax Bill is not clear whether disbursement cost are also included for charging Withholding Tax, says Fiji National Provident Fund (FNPF) Investment principal legal officer Siteri Saru. FNPF made a submission to the Standing Committee on Justice, Law and Human Rights on the Income Tax Bill in… – Continue reading
The Caribbean has just 18 congressional working days from Sunday September 20 to try to have the US Congress or the District of Colombia address an act naming 17 Caribbean nations as “tax havens”. If passed without amendment it could have the effect of reputationally damaging the countries concerned with… – Continue reading
Labour MEP warns that EU tax harmonisation against the interests of Malta and other European islands and peripheral regions Labour MEP and former Prime Minister Alfred Sant told the European Parliament that EU tax harmonisation goes against the interests of Malta and other peripheral regions and islands with limited endowments… – Continue reading
On Friday, Coca-Cola Co. said that it may owe the IRS an extra $3.3 billion in federal income taxes. According to the company, the Internal Revenue Service found after a five-year-long audit that the soft drink giant may owe the federal government $3.3 billion along with interest for the 2007… – Continue reading
The Swiss Bankers Association (SBA) has waded into the ongoing anti-tax evasion political debate by urging lawmakers not to burden banks with too many regulations, reports Swiss Info. The SBA said on Thursday that it supported the introduction of automatic tax data sharing with other countries. However, the lobby group… – Continue reading
European Commission president Jean-Claude Juncker has denied involvement in sweetheart deals that allowed hundreds of multinationals to slash their tax bills by locating to Luxembourg, despite being prime minister of the country for almost 20 years, reports the Financial Times. Facing questions from a committee of EU lawmakers set up… – Continue reading
A small office shared with three other companies deep in the bowels of the Outsource IT Tower on Auckland’s Khyber Pass Road opposite a reservoir isn’t necessarily where you’d expect to find the global headquarters of a financial service provider that claims to be following in the footsteps of three… – Continue reading
Poland’s lower house (Sejm) on 11 September 2015 passed a bill containing amendments to the tax laws, including changes to the rules governing transactions between related parties—the transfer pricing rules. If enacted, the transfer pricing rules would be effective 1 January 2017. Among the legislative changes, new rules would: Increase… – Continue reading
The Internal Revenue Service has issued a notice extending the time under which certain transitional rules for the Foreign Account Tax Compliance Act, or FATCA, will apply. FATCA was included as part of the HIRE Act of 2010 and requires foreign financial institutions to report on the assets of U.S…. – Continue reading
Speed read On 15 September 2015 the Dutch government published its Tax Plan 2016. In this e-alert we discuss the legislative proposals in the Tax Plan which are of interest for companies. 1 INTRODUCTION Today, the Dutch Ministry of Finance published its Tax Plan 2016. In fact, the government sent… – Continue reading
CORNING — Corning Inc.’s handling of profits it earns overseas has quickly become an issue in the 2016 presidential campaign. The Fortune 500 company’s refusal to bring back to the U.S. more than $12.4 billion in overseas profits first drew criticism from U.S. Sen. Bernie Sanders, an independent from Vermont…. – Continue reading
On 16 September 2014, the OECD released the report on the tax challenges of the digital economy (the “Report”) under its Action Plan on Base Erosion and Profit Shifting (“BEPS”). The Report recognises that because the digital economy is increasingly becoming the economy itself, it would be difficult, if not… – Continue reading
Welcome to this special edition of Jones Day’s Global Tax Update. Almost two years ago, the Organisation for Economic Co-operation and Development (“OECD”) launched a radical and far-reaching review of the international tax system. The project’s name, BEPS (base erosion and profit shifting), provides a good insight into its objectives:… – Continue reading
HMRC has today published new draft guidance notes to cover the automatic exchange of financial account information under the International Tax Compliance Regulations 2015 (SI 2015 No. 878) (the Regulations), which were made in the spring. The main document is a new draft HMRC guidance manual covering the Regulations. The… – Continue reading
The 2016 Mexican Economic Package includes a proposal for country-by-country (CbC) reporting of tax information by certain multinational corporations. The Package, which was submitted to Congress by the Government on September 8, 2015, seeks to bring Mexican transfer pricing documentation rules into line with the Organisation for Economic Co-operation and… – Continue reading
Through Wetsvoorstel Overige Fiscale Maatregelen 2016, released on September 15, the Netherlands has confirmed the introduction of a new country-by-country (CbC) reporting obligation for multinational corporations. These regulations provide for the implementation of the recommendations of the Organisation for Economic Co-operation and Development (OECD) on transfer pricing documentation under Action… – Continue reading
The Swiss Federal Council has given the Swiss delegation to the OECD, the “go ahead” to accept the final BEPS reports— expected to be released possibly as early as the end of September 2015. This action indicates that Switzerland could implement and apply the new standards in the near future,… – Continue reading
“I want to commend the government for bringing this bill to parliament,” said Opposition Leader Hon. Dr. Denzil Douglas said today of the government tabled Foreign Account Tax Compliance Act (USA) (Implementation and Enforcement) Bill 2015. During his presentation on the bill’s debate in the National Assembly today (Sept 15),… – Continue reading
Chevron’s tax filings face repeated challenges from the United States and other global tax authorities, according to a new union-backed report that calls on world governments to crack down on the energy giant’s alleged profit-shifting tactics. The world’s largest trade union body, the International Trade Union Confederation (ITUC), has called… – Continue reading
UK tax authority HM Revenue and Customs (HMRC) has published an e-brief on the Scottish Rate of Income Tax (SRIT), which is due to enter into effect from April 2016. From April 1, 2016 the Scottish Parliament will have responsibility for a SRIT. Parliament will be able to set the… – Continue reading
More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development (“OECD”) and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information (“CRS”). Building on the model created by FATCA, the CRS creates a global standard… – Continue reading
SINGAPORE first entered a double taxation agreement (DTA) with Thailand in 1975. After 40 years, Singapore and Thailand signed a new DTA on June 11, 2015. The newly signed DTA has not yet been ratified by either country, and will go into force after it is. Below are some of… – Continue reading
Banks are threatening to close accounts of British expats living in the USA if they fail to complete piles of paperwork to comply with the Foreign Account Tax Compliance Act (FATCA). Millions of US expats worldwide are already caught by the law which requires foreign financial institutions to supply details… – Continue reading
Hong Kong’s Financial Services Development Council (FSDC) has released a report setting out recommendations on policies, including tax measures, to enhance the city’s role as a regional and global financial booking center. Financial institutions utilize such centers to enter into contracts for financial products, undertake primary obligations for delivery or… – Continue reading
Action 6 (Treaty Abuse) is a key element of the OECD’s BEPS Project. Action 6 targets, in summary, “treaty shopping”, i.e., where a person in country A, which is not, in principle, eligible to benefit from a given tax treaty with country B, invests through an entity in country C… – Continue reading
Past Progress and Prospects Harmful tax practices (e.g., tax havens, preferential tax regimes, tax rulings) are characterised by the propensity to erode tax bases of other countries which allegedly leads to an undesirable race-to-the-bottom on taxation rates. Action 5 of the OECD Action Plan on Base Erosion and Profit Shifting… – Continue reading
Read the full newsletter. The OECD’s recent recommendations1 with respect to transfer pricing documentation and country-by-country reporting may have the most significant impact on multinational enterprises (“MNEs”) of all of the OECD’s BEPS proposals. The adoption of these recommendations, without consensus on effective dispute resolution, is likely to alter the… – Continue reading
In a decision released August 14, the Tax Court of New Jersey ruled that an intangible holding company with no physical presence was required to file a New Jersey corporation business tax (CBT) return and pay the related tax due based on its income.1 No relief was available to the… – Continue reading
Some Italian parliament members published a proposal for a new law that may dramatically change the scenario for e-commerce and web operators doing business in Italy. The proposal (called by some commentators as “Digital” or “Web Tax”) is substantially a combination of domestic rules affecting the taxation of the digital… – Continue reading
JAKARTA – Indonesian Institute of Accountants (IAI) considers Indonesia may not completely avoid the impact of the practice of transfer pricing. Therefore, Indonesia must prepare regulatory and law enforcement strong to protect the interests. The practice of transfer pricing is one of the activities of neo-liberalism. According to the National… – Continue reading
The Organisation for Economic Cooperation and Development (OECD) has recommended that Ireland lower its high effective marginal income tax rates, abolish the reduced value-added tax (VAT) rate for the tourism industry, and phase in a planned Local Property Tax (LPT) hike. The recommendations are made in the OECD’s latest Economic… – Continue reading
On September 15, the Dutch government released its Budget 2016, containing the Tax Plan 2016 which includes certain amendments to Dutch tax law. The government will discuss the plans the coming weeks in parliament. Further to these discussions, some elements of the Tax Plan 2016 may change. Most proposals will… – Continue reading
EU committee set up to investigate aggressive tax planning concludes its report in weeks Lobbyists representing internet company Facebook could be banned from entering the European Parliament following a request by the parliament’s special committee on tax to revoke access to multinationals who refused to cooperate with the committee’s inquiries…. – Continue reading
Concerns were raised in parliament Tuesday about the US Foreign Account Tax Compliance Act – FATCA, and its likely impact on the federation. The act, described as a tax act of the American government that the federation is being asked to enforce was being debated in the National Assembly Tuesday,… – Continue reading
The Transactional Net Margin Method (‘TNMM’) is a prescribed method for determining the arm’s length price in some cases. It also enjoins the adjustment owing to capacity under-utilization differences. Sizes of entities and level of activities differ, so does the available comparables for the purpose of transfer pricing adjustments. The… – Continue reading
A federal court judge dismissed an attempt to put an early stop to a controversial program in which the Canadian government agreed to share financial information of an estimated one million “U.S. persons” living in Canada with the Internal Revenue Service. Particularly troubling to some opponents is that the agreement… – Continue reading
On Thursday, The House Ways and Means Committee will once again contemplate making permanent controversial tax breaks that overwhelmingly benefit big business at a cost of $380 billion over the next 10 years. Known as tax extenders, these giveaways are a package of tax breaks that Congress must vote to… – Continue reading
Tax professionals in Australia, in considering how to assess risk and prepare for potential controversy in light of the changing tax landscape, are focusing on a number of key themes. These include the following: The importance of assessing and contrasting positions taken, against positions that the Australian Taxation Office (ATO)… – Continue reading
